Document Sample
					             SMOKE FROM A HIRED GUN :
                   AS P ERFORMED BY ERNST & Y OUNG

                            by Dara O’Rourke

             Transnational Resource and Action Center (TRAC)
                    Presidio Building 1016, 2nd Floor
                              P.O. Box 29344
                         San Francisco CA 94129
                          Tel: (415) 561-6567 (8)
                            Fax: (415) 561-6493
                                                                    Transnational Resource and Action Center

Table of Contents
Forward                                                                                                      3
Executive Summary                                                                                            4
Background -- Nike in Asia                                                                                   6
The Ernst & Young Methodology                                                                                6
Issues Revealed by the Ernst & Young Report                                                                  7
         Chemical Exposures                                                                                  7
         Lack of Safety Equipment and Training                                                               7
         Working Conditions                                                                                  7
Biases in the Audit                                                                                          8
What Ernst & Young Missed                                                                                    9
What Ernst & Young Should Have Analyzed                                                                      9
Conclusions                                                                                                  11
Endnotes                                                                                                     12

About the Author
Dara O’Rourke is a research associate at the Transnational Resource and Action Center (TRAC), and a consultant
to the United Nations Industrial Development Organization (UNIDO) in Vietnam. His research focuses on
strategies for preventing adverse environmental and social impacts of industrial activities. He has been conducting
research in Vietnam for the last three years. Mr. O’Rourke has worked as a consultant to the United Nations
Environment Programme, the World Bank, and the U.S. Environmental Protection Agency. Mr. O’Rourke has a
Bachelors degree from the Massachusetts Institute of Technology in Mechanical Engineering and Political
Science, and a Masters degree from the Energy and Resources Group at the University of California, Berkeley.
He is currently completing his Ph.D. at Berkeley.

About Transnational Resource & Action Center (TRAC)
TRAC works to help build global links for social justice, ecological sustainability and corporate accountability.
Its web site, Corporate Watch <>, provides news, information, analysis for the general
public about the role corporations play in social political, economic and environmental issues in the U.S. and
around the world. TRAC is a project of The Tides Center.

Production Coordinated by Sara Wood

David Atkin, Jeff Ballinger, Nikki Bas, Robert Bray, Andre Carothers, Thuyen Nguyen, John B. Pike, Jaqui
Romualdo, Amit Srivastava.

Exclusive photographs, the first independent pictures taken inside a Nike factory in
Vietnam, will be available on the Corporate Watch Web Site at
<> after November 10th. This report and the entire Ernst &
Young Audit will also be available.

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As public scrutiny of sweatshops in the apparel industry continues to grow, one of the central issues under
discussion is how the global operations of U.S. corporations such as Nike can best be monitored to certify decent
and healthy working conditions.

Indeed, the White House Apparel Industry Partnership, which is due to make a series of recommendations to
President Clinton in November, is currently debating two sides of this question. On the one hand, corporations
on the task force such as Nike argue that accounting firms like Ernst and Young are best qualified to serve as
monitors by carrying out labor and environmental audits. On the other hand, labor, religious and human rights
organizations insist that independent, publicly accountable monitors would be best qualified to undertake this

This debate, however, has been fundamentally flawed by the fact that the public, and most of the members of the
task force, have never seen an audit of labor or health and safety conditions produced by an accounting firm.

TRAC is pleased to be able to shed some light on this subject by releasing the first audit of this kind ever to be
made public: a confidential Ernst and Young assessment of the Tae Kwang Vina plant, a factory which employs
9,200 workers who produce 400,000 pairs of shoes a month exclusively for Nike in Vietnam.

We are also happy to make public the first photos independently taken inside a Nike plant in Vietnam.

Furthermore, we are proud to publish TRAC Research Associate Dara O'Rourke's report, Smoke From A Hired
Gun, an analysis and critique of the Ernst and Young audit.

Mr. O’Rourke is a consultant to the United Nations Industrial Development Organization (UNIDO), and has
conducted research in over 50 factories in Vietnam. One of them was the Tae Kwang Vina factory, a Nike
subcontractor in the Dong Nai province of Vietnam, and the subject of the Ernst and Young audit. Mr. O'Rourke
visited this factory three times in 1997. During the visits to the plant, he performed walk-through audits of
environmental and working conditions, interviewed management personnel, met with Tae Kwang Vina's
managing director, and with representatives of Nike Inc. in Vietnam. He also interviewed workers confidentially
outside the factory--something that Ernst and Young failed to do.

Ernst and Young found Nike’s subcontractor to be in violation of a number of Vietnamese labor and workplace
environmental laws. This finding is in contradiction to Ernst & Young’s own conclusion that Tae Kwang Vina
is in compliance with the Nike “Code of Conduct.”

Furthermore, Mr. O'Rourke found Ernst and Young's methodology to be highly deficient, having ignored “most
accepted standards of labor and environmental auditing.” Mr. O'Rourke's assessment, including his interviews
with workers, reveal a far worse situation in the Nike plant than Ernst and Young portrays.

Indeed, Ernst and Young's incompetence as a social and environmental auditor, combined with Mr. O'Rourke's
own findings inside the plant, present a strong argument against using accounting firms to conduct labor and
environmental audits.

We hope these reports will serve as a constructive contribution to the effort to eliminate sweatshops around the

China Brotsky, Chair of the Board, Transnational Resource & Action Center (TRAC)
Joshua Karliner, Executive Director, Transnational Resource & Action Center (TRAC)

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                                                         Transnational Resource and Action Center

                                    EXECUTIVE S UMMARY

The Ernst & Young Audit
• A confidential Ernst & Young audit of labor and environmental conditions inside a Nike
  factory in Vietnam was recently leaked to the Transnational Resource & Action Center
• This is the first time that an accounting firm's labor and environmental audit of any apparel
  company has ever been made public.
• The question of whether firms such as Ernst & Young are competent to monitor the shoe
  and garment industry is currently under discussion by the White House Apparel Industry
• An examination of the Ernst & Young audit raises serious questions about the legitimacy
  and competence of accounting firms' as independent monitors of labor and environmental
• TRAC is also releasing the first photos taken independently inside a Nike factory in
• The Ernst & Young audit also sheds light on, and raises questions about the findings of
  Andrew Young, the former UN Ambassador hired to evaluate Nike’s “Code of Conduct.”

Ernst & Young on the Conditions inside this Nike Factory
• The Ernst & Young report, which Andrew Young claimed to have access to, shows that
  Nike’s “Code of Conduct,” even when followed, allows dangerous working conditions to
  persist in its plants.
• Although flawed in a number of ways, the audit notes continuing violations of labor laws on
  maximum working hours, unprotected chemical exposures, poor treatment of workers, and
  management control of the trade union.
• Among the factory's 9,200 workers who produce 400,000 pairs of mid- to high-end Nike
  shoes per month, the audit reports high levels of respiratory illnesses in sections with high
  chemical use.
• The audit determined that even though Tae Kwang Vina Company (the subcontractor in
  question) violates Vietnamese labor and environmental laws, it is at the same time in
  compliance with Nike’s “Code of Conduct.”
• Tae Kwang Vina is reportedly the most technically advanced of Nike’s subcontractors in

TRAC's Findings on the Conditions inside this Nike Factory
Confidential interviews with employees outside of the factory provided information about
numerous violations of Nike’s Code of Conduct that were not discovered by the Ernst & Young
audit, including:
• Violations of Vietnamese labor laws on pay;
• Violations of Vietnamese labor laws on maximum overtime hours;
• Forced overtime;
• Strike breaking; and,
• Physical and verbal abuse of workers.

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Shortcomings of the Ernst & Young Audit
• The audit is missing information regarding occupational health and safety, environment, and
   general working conditions.
• The methodology employed by Ernst & Young ignores most accepted standards of labor
   and environmental auditing. For example, the audit involved no monitoring or sampling of
   air quality in the factory.
• Most of the data came directly from management sources.
• The audit overlooks many of the key issues of concern in Nike plants around Asia,
   including: physical and verbal abuse of workers, sexual harassment, repercussions for
   attempts to organize, and contract violations.

Relevance to the White House Task Force
• This audit highlights how important issues can be covered up or ignored in “independent
   monitoring.” Some form of public disclosure is critical to insuring the quality of auditing.
• The audit provides a strong argument against using accounting firms to conduct labor and
   environmental audits.
• The poor quality of this audit argues for truly independent monitoring of Nike plants.
   Labor, religious, or human rights organizations that pass an accreditation program would be
   more appropriate auditors.

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Nike, Inc., the world’s largest retailer of athletic shoes, has come under increasing criticism
recently over working conditions in its factories in Asia. Labor and human rights groups have
reported physical and verbal abuse of workers, hazardous working conditions, pennies per hour
wages, and anti-union efforts throughout Indonesia, China, and Vietnam, where Nike employs
over 350,000 workers.1 Nike’s treatment of its workers stands in stark contrast to the record
$795 million in profits it reported this year.2

Nike initially responded to public criticisms by claiming no control over the conditions inside
the factories making its shoes and clothing. Nike argued that as the company does not own any
of the factories producing its products, Nike could not influence working conditions or pay.3
Labor rights groups have challenged this claim, demanding that Nike take responsibility for its
subcontractors’ actions.

Nike has since changed its strategy. First it hired two public accounting firms, Ernst & Young
and Price Waterhouse, to perform internal audits of the labor and environmental practices inside
its subcontractors. Nike describes the Ernst & Young audits as “systematic, unannounced
evaluations by independent auditors”4 of current working conditions inside their factories.

Second, it hired former UN-Ambassador Andrew Young’s consulting firm GoodWorks
International LLC, to review the company’s “Code of Conduct” and subcontractor compliance.
Andrew Young’s report, which largely exonerated Nike, was made public and followed up with
a PR campaign. The much more in-depth internal audits however, which Andrew Young
claimed to have access to, have remained completely confidential.

These “independent audits” are now central to debates around improving conditions inside the
globally dispersed subcontractors of US firms. A White House commission is currently
examining the issue of independent auditing.5 Nike and other apparel companies in the
commission argue that corporations should be able to employ their own accounting firms to
perform these audits. Labor, religious, and human rights groups however, disagree, arguing
that truly independent auditing is critical to the task of ending sweatshops around the world. A
truly informed discussion of the issue has been limited by the fact that audits by these
accounting firms have never been made public.

Until now, without evidence on the quality of accounting firm audits, it was impossible to
determine whether these firms could, or would, do an adequate job of labor and environmental
auditing. However, just this month, an Ernst & Young audit of one Nike subcontractor – the
Tae Kwang Vina Company, a Korean manufacturer operating in Vietnam – was leaked to
TRAC. Tae Kwang Vina employs 9,200 workers, and produces more than 400,000 pairs of
Nike’s mid- to high-end athletic shoes per month. This audit offers a rare opportunity to
examine the methodology, findings, and recommendations of an industry auditor.


While their methodology is not explicitly presented, Ernst & Young explain that “the procedures
we have performed were those that you [Nike] specifically instructed us to perform.
Accordingly, we make no comment as to the sufficiency of these procedures for your
purposes.” As this statement makes clear, Ernst & Young did not perform an “independent”
audit, but rather simply followed Nike’s instructions.

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The Ernst & Young auditors spent approximately one week in the Tae Kwang Vina factory.6
They relied largely on management information about working conditions, organizational
practices, and wages to write their report. They performed no environmental monitoring or air
sampling of their own. Occupational health and safety information came entirely from
secondary sources (largely Vietnamese government agencies). Information on worker
perceptions and attitudes came from a survey of 50 employees “randomly selected...from the
payroll register.”

The Ernst & Young report, taken on its own, is poorly written, fraught with errors, and
convoluted in structure. As discussed below, the audit methodology and reporting fail to adhere
to the conventions of occupational health and safety, or environmental auditing. Ernst &
Young’s audit procedures appear simply to be based on Nike’s instructions.


Despite methodological flaws, the report does come to a number of striking conclusions about
the working conditions inside Tae Kwang Vina. These include:

Chemical Exposures
• From a “sample of 165 employees from Mixing, P.U., Roller sections, there are 128
  employees (77.57%) getting respiratory disease...” (E&Y Page 9. References in this
  section are to the Ernst & Young Report which is included as an Appendix.)
• “Dust in the Mixing Shop exceeded the standard 10 times.” (E&Y Page 8) This dust
  includes resins that are potentially very hazardous because they cause respiratory ailments.
• Toluene concentrations “exceeded the standard from 6 to 177 times” in several sections of
  the factory. (E&Y Page 8) Toluene is a chemical solvent that is known to cause central
  nervous system depression, damage to the liver and kidneys, and skin and eye irritations.
• Chemical releases have led to an “increasing number of employees who have disease [sic]
  involving skin, heart, allergic, [and] throat working in chemical involved sections.” (E&Y
  Page 8)
• Acetone concentrations “exceeded the standard 6 to 18 times.” (E&Y Page 8)

Lack of Safety Equipment and Training
• “Personal protective equipment (gloves, masks) are not daily provided. (E&Y Page 4)
   Workers “do not wear protective equipment...even in highly-hazardous places where the
   concentration of chemical dust, fumes exceeded the standard frequently.” (E&Y Page 6)
• “There are [sic] no training on proper handling of chemicals for related employees in daily
   exposed [sic] to chemicals.” (E&Y Page 6)

Working Conditions
• Workers are punished or fined for “violating code of section such as talking during working
  hours.” (E&Y Page 3)
• “40 workers [out of 50] do not read NIKE’s Code of Conduct [and] even do not know
  exactly what NIKE is.” (E&Y Attachment II, Page 2)
• “48 cases [out of 50] where workers were required to work above the maximum working
  hours.” (E&Y Page 2)

It is interesting to note that even with these findings Andrew Young concluded that Nike was
doing a “good job.” This would indicate that either Andrew Young was not shown all of the

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internal audits Nike commissioned, or he has a very different view of a “good job” than would
most occupational health and safety specialists.


The Ernst & Young audit methodology results in biased findings on a number of critical issues.
For example, posing a question about pay without guaranteeing protection from repercussions,
can discourage candid answers, and is likely to lead to a biased analysis. As a consultant to the
United Nations Industrial Development Organization in Vietnam, I visited the Tae Kwang Vina
plant three times during 1997. I also interviewed workers in confidence away from the factory.
My research paints a very different picture than the Ernst & Young audit.

Ernst & Young asserts:
       “40 workers [out of 50 interviewed] are satisfied with their salary,” which officially
       starts at $40 per month, although new workers are paid a lower “training wage”. (E&Y
        Attachment 2, Page 2)

        This finding highlights one of the problems with Ernst & Young’s interview method. In
        my research, not one of the workers I spoke with at Tae Kwang Vina (including office
        staff) was “satisfied” with their pay.

Ernst & Young:
       “46 workers opined that working overtime hours are acceptable while 4 workers do not
       appreciate working overtime.” (E&Y Attachment 2, Page 2)

        This statement ignores the deeper rationale for working overtime – base salaries are
        extremely low. Tae Kwang Vina pays one of the lowest base salary of any of the 50
        large factories I have studied in Vietnam.

Ernst & Young:
       Only “15 workers are not satisfied with the working conditions (hot, stuffy).” (E&Y
        Attachment 2, Page 2)

        The workers I spoke with complained about working conditions, including heat,
        chemical exposures, poor ventilation, forced overtime, and verbal abuse by managers.

Ernst & Young:
       “There’s a high rate of labor accidents caused by carelessness of employees.” (E&Y Page

        A serious occupational health and safety audit would analyze the underlying causes of
        accidents – such as the absence of training and hazard prevention programs – rather than
        simply blaming the victims. To attribute accidents to carelessness rather than working
        conditions without thorough analysis is another example of bias in the audit.

Ernst & Young:
       The audit notes that “the workers trade union is still being organized by the management
       and the workers.” (E&Y Page 2)

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        Workers report that leaders of the trade union were selected and paid by Tae Kwang
        Vina’s management.7


In my interviews with employees,8 I was given information about numerous violations of
Nike’s Code of Conduct that were not discovered by the Ernst & Young audit. I was informed
that managers of Tae Kwang Vina have:
• Violated Vietnamese labor laws on maximum overtime hours. Night-shift workers in the
    stitching section told me that their “standard” work week is 10.5 hours per day, six days per
    week. This basic work week can lead to 700 or more overtime hours per year, well over the
    legal maximum of 200 overtime hours per year.;
• Forced overtime. Workers complained that they have no choice in whether or not they work
    overtime. Workers are told one day in advance that they must work overtime. If they
    “choose” not to work overtime more than twice, they are likely to be fired.;
• Violated Vietnamese labor laws on pay. Tae Kwang Vina is required to pay increasing
    wages based on workers’ skills. Workers at skill level 1 should be paid the minimum wage
    ($40/month) times a multiplier, skill level 2 should be paid $40 times a higher multiplier,
    etc. One staff member told me the company ignores this legal requirement, giving annual
    salary increases much lower than required.;
• Broken strikes. Tae Kwang Vina management have repeatedly threatened to fire all workers
    who wouldn’t return to work during strikes over the last two years. An office staff member
    explained that “managers investigate who incited the action, and don’t fire them, but make
    them change jobs, and treat them very badly until they quit.”;
• Physically and verbally abused workers. I was told numerous stories about managers
    hitting workers. Reportedly, in one case the director of security hit a Vietnamese guard. In
    another case, a manager hit several women workers with a broom while trying to force them
    to leave the factory in a single file line.
• Sexual harassment. Several workers told me that a Korean manager allegedly attempted to
    rape two women workers last year, and then fled the country. This was widely reported in
    the Vietnamese press.9 Independent monitors on the ground in Vietnam would have been
    aware of this case and would have followed up on these issues.

Tae Kwang Vina is the most technically advanced of Nike’s subcontractors in Vietnam, and
according to Nike is no worse on labor or environmental issues than the other four Nike
factories in Vietnam.10 In fact, Tae Kwang Vina received the highest score of Nike’s five
factories in Vietnam in a self-assessment procedure.11

The serious omissions and biases in the Ernst & Young findings point out the weaknesses of
using accounting firms to audit labor and environmental practices. These auditors are not
trusted by workers, and their findings are never submitted to public scrutiny.


In following Nike’s instructions for the audit, Ernst & Young failed to comprehensively analyze
labor and environmental conditions inside the Tae Kwang Vina factory. The audit is missing
important information regarding occupational health and safety, environment, and general
working conditions. An audit should be designed to determine normal operating practices
within a factory, to evaluate recognized hazards and how they are controlled, and to analyze
how new hazards are identified and controlled.12 In order to do all this, auditors need to be
trained in hazard recognition, and must be able to independently assess management actions.

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Ernst & Young failed to adequately analyze both existing hazards and procedures for resolving
new hazards.

An Industrial Hygienist who performs worker health and safety compliance inspections for the
State of California13 noted that if Tae Kwang Vina had been operating in the U.S., it would
have been cited and fined on numerous counts, including:
• chemical over-exposures;
• inadequate ventilation;
• noise over-exposures;
• lack of personal protective equipment;
• absence of a hazard communication program;
• lack of job-specific training for operating machinery; and,
• lack of drinking water in high heat stress environments.

The Ernst & Young audit failed to examine any of these issues in detail, and ignored exposures
to other hazardous chemicals such as Methyl Ethyl Ketone and glues in the plant. The audit also
failed to examine why employees with respiratory illnesses were still working in areas of
exposure without controls, and why no safety committee exists in a factory with 9,200

The audit should have also examined issues that are common points of concern in Nike plants
around Asia, and that have been specifically raised at the Tae Kwang Vina plant. Workers
should have been interviewed off-site with guaranteed anonymity regarding physical and verbal
abuse by managers, sexual harassment, general working conditions, and pay issues. Lora Jo
Foo, Managing Attorney for the Asian Law Caucus and President of Sweatshop Watch, asserts
that “it is impossible to do an analysis of minimum wage or overtime compensation without
having information on the actual hours worked, and the take-home pay of the workers, both of
which were missing from the Ernst & Young audit. A proper analysis would involve
unannounced monitoring of working hours, and interviews with workers away from the

The environmental section of the Ernst & Young audit similarly misses most of the key
environmental issues in this factory. At a minimum the audit should have listed all chemicals
used in the plant, noted that burning scrap rubber in the factory’s boilers is violating Vietnamese
environmental laws, and proposed alternatives to burning rubber.

A truly independent audit of labor and environmental practices would involve a more complete
analysis of the system within the factory which affects working conditions, health and safety,
and the environment. This includes: management policies and actions, company organization,
worker training, hazard prevention programs, and existing and potential physical and mental
hazards. A long-term auditing program would also include comprehensive health studies of
workers in hazardous sections of the plant. This type of audit obviously requires well trained
auditors that are committed to independent analysis of the conditions inside the factory.

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Dusty Kidd, Nike’s Director of Labor Practices, proclaims that Nike will “Assure best practices
in every factory where NIKE products are made, regardless of who owns the factory, or the
scale and duration of our presence there.”15 Furthermore, Nike claims that “When NIKE
leads, others follow. We’re the leader -- always have been, always will be.”16 Despite these
bold claims, the leaked Ernst & Young audit provides evidence that working conditions can
hardly be described as “best practices” in a factory which is said to be Nike’s most technically
advanced plant in Vietnam.

The Ernst & Young audit also presents a strong argument that accounting firms retained by
manufacturers are not the appropriate organizations to be conducting audits of labor and
environmental conditions. Accounting firms such as Ernst & Young simply do not have the
training, independence, or the trust of workers, to perform comprehensive, unbiased audits of
working conditions. We agree with a State of California health and safety compliance officer
who argues in an industry newsletter that “putting the fox’s paid consultant in charge of the hen
house” is not the solution.17 It is also clear from the leaked audit that Andrew Young’s report
on Nike failed to examine many of the critical issues related to labor and environmental
conditions in Nike plants.

The information presented in this audit represents only the tip of the iceberg of poor working
conditions inside Nike and other US subcontractor factories around the world. For instance,
there have been widespread reports in the Vietnamese press about similar conditions in other
Nike plants.18 A recent investigative report from China documents serious problems in Nike
and Reebok plants there.19 Nike’s Indonesian factories have been criticized for their
mistreatment of workers for years.20

If Nike genuinely wishes to improve the conditions inside its plants, it would, as the saying
goes, “Just Do It.” The company should make public all of the internal audits conducted to
date. This would shed light on current conditions in its plants, and increase the public’s belief
that Nike is making a good faith effort to improve.

Clearly only well-trained, independent auditors can perform the types of audits that are needed
in Nike’s factories. As The New York Times admits, a better alternative to accounting firms
would be “local, truly independent monitors who speak the language, can make unannounced
visits and enjoy the trust of a largely young, female...workforce.”21 Labor, religious, or
human rights groups that pass an accreditation program would be the best candidates for this

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  Dottie Enrico, “Women's Groups Pressure Nike on Labor Practices,” USA TODAY, October 27, 1997, Pg.
2B; Jon Frandsen, “Nike Invited to Answer Charges of Third World Exploitation,” Gannett News Service,
October 24, 1997; Brad Knickerbocker, “Nike Fights Full-Court Press on Labor Issue,” The Christian Science
Monitor, September 23, 1997; Jonathan Make, “Critics: Young Report Just Doesn’t Do It,” Business Journal-
Portland, June 27, 1997.
  PRNewswire, “Nike Reports Record Fourth Quarter and Fiscal 1997 Earnings,” July 1, 1997, Beaverton, Ore.
  Donald Katz, Just Do It: The Nike Spirit in the Corporate World, New York: Random House, 1994. Katz
quotes one Nike representative as saying “We don’t pay anybody at the factories and we don’t set policy within
the factory; it is their business to run.”
  See Nike’s web page
  The Apparel Industry Partnership was created by the White House in August 1996. In April 1997, the
Partnership presented the President with a Code of Conduct and Principles of Monitoring. The Partnership plans
to release a second report in November 1997.
  Personal communication with Nike staff in Ho Chi Minh City, Vietnam, October 3rd, 1997.
  Interview with Tae Kwang Vina employee, October 7, 1997.
  Interviews were conducted with five Tae Kwang Vina employees in October, 1997. These employees ranged
from high-level office staff to factory workers.
  The Worker Newspaper (Nguoi Lao Dong), in Vietnamese, August 23, 1996. See also Duc Hung and Huong
Lam, “Foreign Bosses Blasted: Labour Force Abused as Firms Seek Short Cut to Quick Buck,” Vietnam
Investment Review, Ha Noi, March 3-9, 1997.
   Personal communication with Nike staff in Ho Chi Minh City, Vietnam, October 3rd, 1997.
   Interview with Tae Kwang employee, October 11, 1997.
   Arthur Reich, “Workplace Inspection & Worker Protection,” in J. LaDou (ed.) Occupational Health & Safety,
Itasca, Illinois: National Safety Council, Second Edition, 1994, PP: 121-161. Elizabeth Gross and Elise Pechter
Morse, “Evaluation,” in B.A. Plog, J. Niland, and P.J. Quinlan (eds.) Fundamentals of Industrial Hygiene,
Itasca, Illinois: National Safety Council, Fourth Edition, 1996, PP: 453-483.
   Personal communication with Garrett Brown, MPH, Industrial Hygienist, Nov. 2, 1997. Mr. Brown is a
compliance inspector for the State of California, and is the National Coordinator of the Maquiladora Health and
Safety Support Network.
   Personal communication with Lora Jo Foo, October 31, 1997.
   See Nike’s web page
   Garrett Brown, “The Slippery Slope of Third-Party Reviews,” The Synergist, September 15, 1997.
   Articles in Vietnamese and English are available from Vietnam Labor Watch or on their web site at:
   The Asia Monitor Resource Centre and the Hong Kong Christian Industrial Committee, "Working Conditions
in Sports Shoe Factories in China Making Shoes for Nike and Reebok," Hong Kong, September 1997.
   David Moberg, “Just Doing It: Inside Nike’s New-Age Sweatshop,” L.A. Weekly, June 20, 1997. Jeff
Ballinger, “Just Do It - or Else: Unfair Labor Practices Among Nike Inc.’s Foreign Suppliers,” Multinational
Monitor, v16, n6, June 1995.
   New York Times, “Watching the Sweatshops,” Editorial, p. A20, August 20, 1997.

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